In Van v. Grant & Weber, the Court of Appeals for the Ninth Circuit held in an unpublished decision that including in collection letters certain location obligations permitted under the Rosenthal Act does not violate the FDCPA. The Court of Appeals explained:
Van argues that this statement is misleading because California Civil Code § 1788.21(b) requires such notification only in the event the creditor clearly discloses that requirement in writing in the original agreement. Consequently, Van argues that the allegedly misleading statement violated several provisions of the FDCPA. We affirm. ¶ Grant & Weber’s letter did not misstate California Civil Code § 1788.21. Under California law, with respect to “any consumer credit existing or requested to be extended,” a debtor “shall within a reasonable time notify the creditor . . . of any change in [the debtor’s] name, address, or employment,” Cal. Civ. Code § 1788.21(a) (emphasis added), but “only if and after the creditor clearly and conspicuously in writing discloses such responsibility,” Cal. Civ. Code § 1788.21(b). On its face, the requirement to notify creditors of specified changes applies to previously-existing credit, as is the situation in the case at issue. The law contains no requirement that the notification be in the original agreement extending credit, and we decline to interpret the statute to include such language.